Appropriate Guidance

[Tom Sutton]

My understanding about selecting the appropriate guidance, is if it is a new build, you should use the building regulations guidance ADB, BS 9999 or BS 7974 and decide which one to use, you shouldn?t cherry pick. If it is an existing building you should use the appropriate DCLG guidance or other appropriate guidance, considering any previous guidance that may have been used.

Is this more or less correct or am I well out of touch with modern day thinking.

[Bruce89]

That's how I understand it in principle i.e. ADB, 9999 etc. Design documents, DCLG guidance for existing buildings. I don't think you are out of touch at all.

[kurnal]

Yes the principle is fine and it's the huge shortcomings of the DCLG guidance that often makes it necessary to think outside its confines and then where do you go? You can only  use other guidance, e.g. Sections of ADB etc as a signpost to what might be an acceptable solution as I think you are suggesting Tom.

For new build you are right that a single source of guidance should ideally be used. Cherry picking would for example involve the use of travel distance or exit width tables from 9999 and applying them in an otherwise ADB project without the other safeguards in 9999 such as management levels. That would be wrong.

Butsometimes the client requirement or architects aspirations take you outside the guidance yet do not justify a full engineered solution. Take for example a slight limitation to fire service access compared to B5? In such circumstances it's fine to stick with rhe ADB approach and to use parts of other guidance or engineering principles  as a source of reference to come up with a solution. That's problem solving not cherry picking.

Similarly there's  no practical guidance on sprinkler systems in any of the quoted standards - the sprinklers may be required to form part of an engineered solution or for compartmentation considerations but the BSEN solution quoted in the BS and ADB  has a number of limitations making their use impractical for that particular scenario, Then some imagination and reference to other guidance is justified e.g. NFPA or FM. Some may call this  cherry picking But I call it real world pragmatism.

[AnthonyB]

The DCLG Guidance would be better if updated and written in the style of the LGA Guide & draft specialist housing guide, it would certainly help with the varying styles of building and changes in guidance applied to existing buildings over the post war years.

Cherry picking is dangerous especially with respect to BS9999, which is meant to be a complete package, not a pick & mix selection.

[colin todd]

Ah what a discerning man you are, Tony.

[idlefire]

My understanding about selecting the appropriate guidance, is if it is a new build, you should use the building regulations guidance ADB, BS 9999 or BS 7974 and decide which one to use, you shouldn?t cherry pick. If it is an existing building you should use the appropriate DCLG guidance or other appropriate guidance, considering any previous guidance that may have been used.

Is this more or less correct or am I well out of touch with modern day thinking.

My understanding is that both the Regulatory Reform (Fire Safety) Order 2005 and Building Regulations 2010 are based on function requirements, Article 50 guidance and the suite of Approved Documents (respectively) are provided as guidance in support of these pieces of legislation.  

Prescriptive application of these guidance documents SHOULD help achieve compliance with the legislation, but not in all cases.  This "guidance" merely sets benchmark standards, although other guidance is also available, and there are many "determinations" which have shown that it is not necessary to adhere prescriptively to the guidance to achieve compliance.

Most of the guides do suggest that you should use them exclusively and not "cherry pick" between guides although, in reality, sometimes there may be no alternative.

The bottom line is that you have to convince the appropriate enforcing authority that you have complied with the functional requirements of the appropriate legislation; also, AI's, Building Control and Fire & Rescue Authorities don't always agree on what constitutes compliance.

[wee brian]

If you are going to get all precise then its worth noting that Approved Documents have a statutory status whereas the Risk Assessment guides do not.  In practice it doesn't make all that much difference, they are used to set a benchmark.

[Tom Sutton]

Check out https://www.gov.uk/government/collections/fire-safety-law-and-guidance-documents-for-business answers my question, no mention of the approved documents to enforce the RR(FS)O. As for cherry picking there should be no need, simple apply risk assessment.

[Davo]

Tom

Indeed so, the original ADs were designed so businesses could carry out FRAs themselves without extra financial burden.


davo

[Fishy]

As regards design, you certainly shouldn't 'cherry pick' the bits that you like from the relevant Government guidance (ADs, Technical Standards or whatever) and combine them with the parts of BS 9999 that suit you - the new version of the latter has significantly strengthened its recommendations that this is bad practice.  BS 7974 is different, though, because in my experience it would be practically unachievable (certainly very time consuming) to try and design a building using only BS 7974.  What we instead tend to do is to use the bulk of one of the other pieces of guidance with BS 7974 being used to justify non-conformances with certain aspects of the chosen guidance (e.g. using ASET/RSET analysis to justify means of escape distances in excess of those recommended).  Therefore practically speaking an approach that uses BS 7974 is almost inevitably going to be reliant upon 'cherry picking'.

Risk assessment under the FSO should (in my view) always at least consider the Government-issued guidance - my reasoning being that if you choose not to follow it then you ought to be able to explain to someone wearing a funny wig why you took that decision, and why your alternative approach achieved an equivalent level of fire safety.

[SeaBass]

Irrespective of which design guide is used by the architect or designer, the proposed design should be subject to a QDR process to ensure that the  completed building is suitable for the occupancy risk profile and enables the ongoing use of the building in compliance with the FSO 2005. It is not uncommon for aspects of the FS design of BCO approved buildings to contravene  the requirements of the FSO, particularly where fire engineered or managed solutions are introduced.

[idlefire]

Irrespective of which design guide is used by the architect or designer, the proposed design should be subject to a QDR process to ensure that the  completed building is suitable for the occupancy risk profile and enables the ongoing use of the building in compliance with the FSO 2005. It is not uncommon for aspects of the FS design of BCO approved buildings to contravene  the requirements of the FSO, particularly where fire engineered or managed solutions are introduced.

Have I missed something, do Building Regulations and Fire Safety Procedural Guidance and the Article 45 "duty to consult enforcing authority before passing plans" no longer apply? 

[AnthonyB]

Irrespective of which design guide is used by the architect or designer, the proposed design should be subject to a QDR process to ensure that the  completed building is suitable for the occupancy risk profile and enables the ongoing use of the building in compliance with the FSO 2005. It is not uncommon for aspects of the FS design of BCO approved buildings to contravene  the requirements of the FSO, particularly where fire engineered or managed solutions are introduced.

Have I missed something, do Building Regulations and Fire Safety Procedural Guidance and the Article 45 "duty to consult enforcing authority before passing plans" no longer apply? 

Wasn't it said on here a few years back that some brigades due to resource issues don't respond to all consultations anymore?

I know of a few sites where the FRS has had issues with something in a new build a couple of years down the line that were clearly represented in the original proposed plans and proposed fire strategy, yet at the time of consultation they raised no objections so it was put in and signed off.

[Dinnertime Dave]

Irrespective of which design guide is used by the architect or designer, the proposed design should be subject to a QDR process to ensure that the  completed building is suitable for the occupancy risk profile and enables the ongoing use of the building in compliance with the FSO 2005. It is not uncommon for aspects of the FS design of BCO approved buildings to contravene  the requirements of the FSO, particularly where fire engineered or managed solutions are introduced.

Have I missed something, do Building Regulations and Fire Safety Procedural Guidance and the Article 45 "duty to consult enforcing authority before passing plans" no longer apply? 

Yes, a duty to consult. However, FRS only have an obligation to respond. Many don't.

I sat at Moreton on courses a few years ago and some IOs laughed at the thought of making the responses that I made. My thoughts were at least I've told you my opinion. Very often AI or LA BCOs didn't reply to my comments or said they would pass things on if they thought they were relevant.